When a shareholder waives a shareholder loan under the under the condition subsequent of the improvement of the economic position of a corporation, continued incurring refinancing cost at the level of the shareholder are not tax deductible in connection with previous interest income. Such interest expenses are then regarded as related to investment income may, upon application, only be deducted at a rate of 60% as income related expenses (Decision by the Federal Fiscal Court dated October 24, 2018).